Fourteen-Forty Private Investigators & Security Consultants, in its capacity in conducting investigations, will gather information pertinent to the matter at hand. As a licensed agency through the Ministry of Community Safety and Correctional Services of Ontario, Fourteen-Forty collects personal information on individuals where there is a potential contravention of the law or breaches of agreements or other circumstances that permit us to legally collect this information under the laws of Canada.

In collecting, using and retaining personal information through the course of business activities, we undertake and respect the protection of personal information gathered, ensuring its safekeeping. In accordance with the federal Personal Information Protection and Electronics Documents Act (PIPEDA), we employ the Ten Privacy Principals, which were established by the Canadian Standards Association’s Model Code for the Protection of Personal Information and are at the heart of the Act.

1. Accountability
Fourteen-Forty will be responsible for all personal information under its control and has designated a Privacy Officer to help ensure Fourteen-Forty’s compliance with this Policy and Fourteen-Forty’s Code of Conduct.

Should Fourteen-Forty engage a third party to process personal information, we will use reasonable means to ensure that all third party transferring of personal information is afforded a comparable level of protection to that which Fourteen-Forty maintains.

2. Identifying purposesAt or before the time of collection and throughout the course of dealings with an investigative file as deemed necessary, Fourteen-Forty will identify and disclose the purpose for which personal information is to be collected on affected individuals. All assignments received from Fourteen-Forty clients will be vetted to ensure their requests for information are compliant with PIPEDA.

3. Consent
We will obtain the appropriate consent from individuals for collection, use or disclosure of personal information, except where the law provides an exception. We may obtain express consent for the collection, user disclosure of personal information, or when we determine that consent has been applied by the circumstances.

Express consent is specific authorization given by the individual to Fourteen-Forty, either orally or in writing. Implied consent is when Fourteen-Forty has not received a specific consent but the circumstances allow us to collect, use, or disclose personal information.

In most incidences, obtaining the knowledge and consent of individuals would defeat the purpose of an investigation, in particular with respect to a breach of an agreement or contravention of a law. Personal information will only be collected, used and disclosed by Fourteen-Forty without consent in accordance with Section 7 of the Personal Information Protection and Electronics Documents Act, S.C. 2000, c.5 (PIPEDA) or under other lawful means.

4. Limiting collection
The personal information that we collect will be limited to that which is necessary for purposes we have identified. We will only collect personal information for specific, legitimate purposes. We will not collect personal information indiscriminately. We will only collect information by fair and lawful means and not by misleading or deceiving individuals about the purpose for which the information is being collected. Our policies and procedures relating to the limitations on collection of personal information will be regularly communicated to investigators who deal with collection, use and disclosure of personal information.

5. Limiting use, disclosure and retention
Personal information will not be used or disclosed for purposes other than those for which it is collected, except with the consent of the individual or as permitted by law. We will only retain personal information as long as necessary for the fulfillment of those purposes. Personal information that is no longer required to fulfill identified purposes will be destroyed, erased, or made anonymous.

Please note that there may be situations where Fourteen-Forty uses, discloses or retains personal information for legitimate purposes not identified to the individual to which the information pertains including those situations referred to in Section 3.

6. Accuracy
The personal information collected will be accurate, complete and up-to-date as necessary for its intended purposes. Our goal is to minimize the possibility that inappropriate information may be used to make a decision about any individual whose personal information we process.

Should an error or omission be identified, Fourteen-Forty will correct or amend the information as appropriate. Where necessary, we will send such corrected or amended information to third parties who have had access to the information in question.

7. Safeguards
Fourteen-Forty will safeguard all personal information under its control in a manner that is appropriate to the sensitivity of the information. Physical security measures include alarming and locking of facilities and/or locking all personal information in secure filling cabinets.

Fourteen-Forty investigators and associates are trained in the policies of that pertain to these safeguards. Members of the public are not allowed free access to our facilities. While every effort to hand deliver only hard copy information in relation to investigations conducted, Fourteen-Forty will take care in ensuring only the rightful recipient receives information, when information needs to be transmitted in electronic form. Distribution of personal information is conducted on a need-to-know basis.

Precautions are taken in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to information. These measures include ensuring that document and other analog or digitally converted media records (such as audio/video tapes, CDs) are shredded or otherwise destroyed before discarding them so no one may retrieve personal information after disposal.

8. Openness
Fourteen-Forty will make available to individuals who request it, information about our policies and procedures relating to the management of personal information that is under its control.

9. Individual access
Upon request, an individual will be informed of the existence, use and disclosure of his/her personal information which is under the control of Fourteen-Forty, and may be given access to and be permitted to challenge the accuracy and the completeness of that information.
There are lawful exceptions that would prevent us from providing access to information, which include, but are not limited to the following:

Personal information about another person might be revealed.

Commercially confidential information might be revealed.

Someone’s life or security might be compromised.

The information was collected without consent for the purposes related to an investigation of a breach or an agreement or contravention of a law or other lawful exemption.

The information was generated during the course of a formal dispute resolution process.

The information is protected by the Solicitor/Client privilege.

When restricted from providing this disclosure under any section of the Private Security and Investigative Services Act and Regulations of Ontario 2005, S.O. 2005, c.34

10. Challenging compliance
An individual may address a challenge concerning compliance with the aforementioned policies and procedures to our Privacy Officer whose details are listed in Section 1. Responses will be addressed within 30 calendar days of receipt of any inquiry or request.

Fourteen Forty has also developed a Code of Ethics so that our clients and the general public can be assured that certain guidelines will be followed through the course of business conducted by Fourteen-Forty Private Investigators & Security Consultants.

Any person or organization involved in investigation and other business on behalf of Fourteen-Forty shall adhere to Fourteen-Forty’s Privacy Policy.

The president of Fourteen-Forty will conduct due diligence before any investigation is commenced to ensure the identity of the client, and that the investigation is for a lawful purpose.

No information shall be collected, used or retained for personal purposes.

No false or misleading claims or statements shall be made by Fourteen-Forty or its associates regarding our qualifications or abilities or that of any other investigative body.

No false or misleading information or opinions with respect to investigations and related findings shall be provided or reported, adhering to accurately factual information that is objective and unbiased, and within the confines of Fourteen-Forty’s Privacy Policy and the law. Reports will be provided in written, hard-copy format, unless otherwise requested by the client.

Any investigator acting on behalf of Fourteen-Forty shall immediately disclose to the president of Fourteen-Forty any conflict of interest regarding an investigation so that the president may immediately take the necessary action to ensure that the identified conflict does not compromise the investigation, the reputation of the client, or the safety of the client or subject(s) of the investigation.

Fourteen-Forty will disclose to the client applicable rates and charges before the commencement of an investigation or security consultation. During the course of an investigation, Fourteen-Forty will provide up-to-date accounting of current costs in the event that a set budget is expressed by the client. Should the client’s maximum budget be reached before the investigation is concluded, the president will cease all investigative activity unless consent from the client is received to continue, thereby exceeded the originally expressed budget.